The Senate passed the Economic Growth, Regulatory Relief and Consumer Protection Act (S.2155) on March 14 by a filibuster-proof vote of 67 – 31.  The Senate bill still must pass the House, where Rep. Jeb Hensarling (R-TX) and other representatives have said they plan to propose a series of amendments … Read More

The Bipartisan Banking Bill would provide banking organizations with relief from their stress testing, capital and liquidity requirements by adjusting the thresholds, frequency and substance of these rules.  The bill – which recently passed in the Senate, as described in a recent post here – is now being considered in … Read More

The Senate has passed the Bipartisan Banking Bill, which would raise the generally applicable statutory threshold for most enhanced prudential standards (EPS) from $50 billion to $250 billion in total consolidated assets and would provide other targeted relief to regional and community banks.  It would also make a … Read More

In a long-awaited report to the President, the Treasury Department recommended reforming—but not repealing—the orderly liquidation authority (“OLA”) created by Title II of the Dodd-Frank Act (“Title II”), while also recommending the addition of a new Chapter 14 to the Bankruptcy Code.  Concluding “unequivocally that … Read More

In his recent speech that we have covered in a series of blog posts, Federal Reserve Vice Chair for Supervision Randal Quarles announced that he would like the Federal Reserve to achieve “meaningful simplification of our framework of loss absorbency requirements,” referring to both the Federal Reserve’s capital and … Read More

The Senate’s bipartisan regulatory relief bill advanced out of the Senate Banking Committee this week with only minor changes and remains on a path to a filibuster-proof majority.  The bill would provide regulatory relief to regional, community and custody banks, among others—as described in two earlier posts here and hereRead More

Does the bipartisan Senate bill described in our earlier post leave large banks, i.e., banking organizations with $250 billion or more in total consolidated assets, and foreign banking organizations (FBOs) entirely out in the cold?  No, but the relief it provides to large banking organizations is quite limited, and it … Read More

The bipartisan Senate bill would open the door to welcome relief for regional and community bank holding companies (BHCs) by raising the statutory threshold for enhanced prudential standards from $50 billion to $250 billion in total consolidated assets.  The bill, titled the Economic Growth, Regulatory Relief and Consumer Protection ActRead More

The Leveraged Lending Guidelines are in an uncomfortable state of limbo.  After the GAO ruling that the Guidelines are a “rule” under the Congressional Review Act, they are no longer effective as guidance, but the silence from the OCC, the Federal Reserve, and the FDIC has been deafening.[1] The uncertainty … Read More